Law School Case Brief
Ledbetter v. Goodyear Tire & Rubber Co. - 550 U.S. 618, 127 S. Ct. 2162 (2007)
Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., makes it an unlawful employment practice to discriminate against any individual with respect to his compensation because of such individual's sex. 42 U.S.C.S. § 2000e-2(a)(1). An individual wishing to challenge an employment practice under this provision must first file a charge with the Equal Employment Opportunity Commission (EEOC). 42 U.S.C.S. § 2000e-5(e)(1). Such a charge must be filed within a specified period (either 180 or 300 days, depending on the state) after the alleged unlawful employment practice occurred and if the employee does not submit a timely EEOC charge, the employee may not challenge that practice in court, § 2000e-5(f)(1).
During most of the time that petitioner Ledbetter was employed by respondent Goodyear, salaried employees at the plant where she worked were given or denied raises based on performance evaluations. Ledbetter submitted a questionnaire to the Equal Employment Opportunity Commission (EEOC) in March 1998 and a formal EEOC charge in July 1998. After her November 1998 retirement, she filed suit, asserting, among other things, a sex discrimination claim under Title VII of the Civil Rights Act of 1964. The District Court allowed her Title VII pay discrimination claim to proceed to trial. There, Ledbetter alleged that several supervisors had in the past given her poor evaluations because of her sex; that as a result, her pay had not increased as much as it would have if she had been evaluated fairly; that those past pay decisions affected the amount of her pay throughout her employment; and that by the end of her employment, she was earning significantly less than her male colleagues. Goodyear maintained that the evaluations had been nondiscriminatory, but the jury found for Ledbetter, awarding backpay and damages. On appeal, Goodyear contended that the pay discrimination claim was time barred with regard to all pay decisions made before September 26, 1997--180 days before Ledbetter filed her EEOC questionnaire--and that no discriminatory act relating to her pay occurred after that date. The Eleventh Circuit reversed, holding that a Title VII pay discrimination claim cannot be based on allegedly discriminatory events that occurred before the last pay decision that affected the employee's pay during the EEOC charging period, and concluding that there was insufficient evidence to prove that Goodyear had acted with discriminatory intent in making the only two pay decisions during that period, denials of raises in 1997 and 1998.
Were Ledbetter’s arguments that her paychecks and a raise denial each violated Title VII and triggered a new charging period meritorious?
The Court held that Ledbetter’s arguments that her paychecks and a raise denial each violated Title VII and triggered a new charging period could not be reconciled with caselaw. The on-going effects alone could not breathe life into prior, uncharged discrimination. Ledbetter’s attempt to take the intent associated with prior pay decisions and shift it to the later pay decision was unsound. The Court rejected the argument that it adopt a special rule for pay cases noting that the particular characteristics of this case was certainly not representative of all pay cases and may not have even been typical. The Court held that Ledbetter’s policy arguments for giving special treatment to pay claims found no support in the statute and was inconsistent with Supreme Court precedents.
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